Privacy Notice - European Union

EU Safe Harbor Privacy Policy

THIS PRIVACY POLICY DESCRIBES HOW INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU MAY OBTAIN ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

Optum, Inc. is committed to protecting the privacy of the information you provide to us or that we create on your behalf when providing services to you. This information may include both health related information and other personal information such as your name, identification number, address, and phone number.

Although our services are related to your health, Optum is not a medical treatment provider and our staff cannot provide medical treatment, diagnosis, or monitoring. Optum programs should not be relied upon as a substitute for professional medical advice. Optum programs are intended to assist you with personal health improvement efforts through coaching, education, and instruction. Always continue to seek the advice of your doctor with any questions you may have regarding your medical conditions.

Optum adheres to the EU-US Safe Harbor Framework (the “Safe Harbor”) and related privacy principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement. Additional information about these principles and the Safe Harbor is available on the U.S. Department of Commerce website atwww.export.gov/safeharbor.The purpose of this privacy policy is to inform Optum participants who may reside in European Union (“EU”) countries regarding how Optum may utilize information consistent with the Safe Harbor principles.

Notice

Optum operates as a covered entity under the U.S. Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Consistent with the privacy and security standards within HIPAA, Optum uses and shares health information in a number of ways connected to our health related services, payment, and our operations. Some examples of how we may use or share your health information are listed below.

Health related services.

·To our employees or other members of our workforce involved with providing you your health related services.

·To your health care providers who may request information about you.

Payment purposes.

·To bill or administer your health benefits policy or contract.

·To other organizations and providers for payment activities unless disclosure is prohibited by law.

Health care related operations.

·To administer and support our business activities, we give information to organizations that will survey on our behalf for satisfaction, quality, and/or program outcomes, or those of other health care organizations as allowed by law including providers and plans.

·To other individuals such as consultants and attorneys and organizations that help us with our business activities. If we share your health information with other organizations for these purposes, they must agree to protect your privacy.

Contacting you: Your information may also be used to contact you. For example, we may contact you by postcard, phone, voicemail, or email to remind you of an appointment you have with us.

Onward Transfer

We may contract with third parties to perform certain functions on our behalf. Any such third parties are under a contractual obligation to use information received from Optum only for purposes that fall within the functions for which they were hired, and otherwise consistent with the requirements for business associate agreements under HIPAA. We may also use or share information that we collect about you when we have reason to believe it is necessary to identify, contact or bring legal action against persons who may harm you, us, or others. We may also disclose information when we believe the law requires it.

Choice, Access, and Enforcement

Rights Regarding Your Information. You have specific rights regarding the use and disclosure of your information. You have the right to:

·Request to receive and inspect copies.In most cases, you have the right to look at or order a copy of your health related record by using an Authorization to Release Health Information Form provided by calling us at 1-866-QUIT-4-LIFE (784-8454). You may be charged reasonable fees for copies provided.

·Request an amendment.If you believe that information is incorrect or missing, you have the right to request in writing that we correct the existing information or add the missing information. In your request, you must give a reason for the change. We are not required to amend the record, but a copy of your request will be added to the record if you direct us to file it.

·Request to know about disclosures.You have the right to request in writing a list of certain disclosures of your health information. The accounting of disclosures will not include disclosures to those related to providing treatment, payment, health care operations, or when you have authorized the disclosure. You may receive one list per year at no charge. You will be charged a processing fee for each additional request within the same twelve-month period.

·Request restricted use.You have the right to ask us in writing to restrict certain uses and disclosures of your information. We are not required to grant the request but we will comply with any request we grant.

·Request how we communicate.You have the right to request in writing that we communicate with you by another means. For example, you may ask us to contact you at work or at a different address. We are not required to grant the request, but we will comply with any request we grant.

·Make a complaint.If you think that we may have violated your privacy rights or you disagree with a decision we made about access to your information, you may file a written complaint with our Privacy Office. You will not be penalized or retaliated against if you file a complaint.

·Right to receive a copy of this Policy. You have the right to receive a paper copy of this Policy, even if you have already received it previously.

Data Security and Integrity

We will take reasonable precautions to protect the security and integrity of any personally identifiable information that we collect, maintain, use or disclose through the provision of services to participants. We will take reasonable steps to ensure that data is reliable for its intended use, accurate, complete, and current.

Changes to Privacy Policy: Optum, Inc. may change the terms of this Policy at any time. The revised Policy would apply to all information that we maintain. If you have any questions about this Policy or would like an additional copy, please contact the Privacy Officer at 1-866-QUIT-4-LIFE (784-8454).